3:13-cv-01223-JFA Date Filed 04/22/14 Entry Number 49 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION

UNITED STATES OF AMERICA, THE ]

STATES OF CALIFORNIA, ]
DELAWARE, FLORIDA, GEORGIA ]
HAWAII, ILLINOIS, INDIANA, IOWA, ]
MASSACHUSETTS, MINNESOTA, ]
MONTANA, NEVADA, NEW JERSEY, ]
NEW MEXICO, NEW YORK, NORTH ]
CAROLINA, RHODE ISLAND, ]
TENNESSEE, VIRGINIA, AND THE ]
DISTRICT OF COLUMBIA, ]
]
Plaintiffs, ]
]
Ex rel. LAURENCE SCHNEIDER, ]
]
Plaintiff-Relator, ]
]
v. ] Civil Action No.: 3:13cv1223
]
J.P. MORGAN CHASE BANK, ]
NATIONAL ASSOCIATION, J.P. ]
MORGAN CHASE & COMPANY; AND ]
CHASE HOME FINANCE LLC, ]
]
Defendants. ]

MOTION FOR EXTENSION OF TIME TO SERVE COMPLAINT

Comes now, Plaintiff-Relator, by and through his undersigned counsel of record, and

moves this Honorable Court for an Order extending time to serve the Complaint on Defendants.

In support of the Motion, Plaintiff-Relator shows as follows:

1. On March 24, 2014, this Court permitted Plaintiff-Relator’s previous counsel to

withdraw. (Dkt. Doc. No. 45.) The Court provided Plaintiff-Relator forty-five (45)

days to secure substitution counsel and serve the Complaint. The due date for service

is April 26, 2014, a Sunday.

 3:13-cv-01223-JFA Date Filed 04/22/14 Entry Number 49 Page 2 of 2

2. Plaintiff-Relator diligently searched for counsel and retained Strom Law Firm, LLC,

on April 22, 2014.

3. Counsel will attempt to secure service on Defendants but respectfully requests an

additional thirty (30) days to serve the Complaint in a abundance of caution.

Wherefore, Plaintiff-Relator requests he have until May 27, 2014 to serve his Complaint

on Defendants.

RESPECTFULLY SUBMITTED, this 22nd day of April, 2014.

S/Mario A. Pacella
STROM LAW FIRM, LLC
J. Preston Strom, Jr. (Fed. I.D. No. 4354)
Mario A. Pacella (Fed I.D. No. 7538)
2110 Beltline Boulevard
Columbia, South Carolina 29204
Tel: 803.252.4800
Fax: 803.252.4801